Prospects of Strategic Environmental Assessment (SEA) in Pakistan:
Case Study of ‘Clean Drinking Water for All’ (CDWA) Programme
Authors: Nazia Zakir Ahmed and Dr Raja Aurangzeb Khan
1
Abstract
In February 2001, the Ministry of Environment presented National Environmental Action Plan (NEAP) to
the Environmental Protection Council, where one of the core areas was clean drinking water. The action
plan aimed to achieve targets of Millennium Development Goal-7 by providing clean drinking water to
general public. To achieve the targets, Government of Pakistan initiated Clean Drinking Water Initiative
(CDWI) in 2004 followed by Clean Drinking Water for All (CDWA) programme in 2006. CDWI planned to
install one Water Filteration Plant (WFP) at each district, later, one at each Tehsil (406). Whereas, CDWA
further expanded to one WFP at each Union Council (6635). However, the programme failed to produce
desired results as risks associated to social, economic and environmental aspects were not analyzed
prior to execution. Besides, the programme faced sustainability issues due to no attention paid to post
installation maintenance and operation. A number of WFPs (33%) are not functional due to nonavailability of electricity. Since Strategic Environmental Assessment (SEA) is not a legal requirement in
Pakistan, therefore, plans, policies, regulations, and programmes covering wider areas are not assessed
strategically. SEA is new concept that allows identification of risks at an earlier stage, where, they can be
addressed in the programme design. Many similar projects underway that require SEA, thus, there is a
need to develop capacity of relevant institutions and personnel for incorporating SEA into programmes
and policies. This paper analyses the case of CDWA programme and demonstrates on how principles of
SEA when applied at an earlier stage could enhance programme design and implementation. It will also
provide an analysis on future application of SEA and challenges that may arise in context to Pakistan.
Key words: SEA, policies, legislation, water, design, implementation.
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Introduction
2.1
Pakistan covers an area of 796,096 Km2 with a population of 149.860 million (Pakistan Demographic
Survey – 2007) and an average annual growth rate of 2.69 % (1981-98). The country has four provinces
and four territories which are further sub-divided into 132 districts and seven tribal agencies. There are
more than 544 tehsils, 6600 union councils and 30,000 villages in Pakistan. A nation-wide survey report
on the state of the drinking water supply and usage has suggested that only 19.4 per cent 1 of the people
have confirmed access to clean and safe drinking water in Pakistan. The report says, "77 percent of the
rural population does not have government water supply provisions, where 54 per cent have access to
drinking water through hand pump or motor pump, 5.8 per cent through river/lake/canal, 14.4 per cent
from fountain, 3 per cent from well and 1.3 per cent use bottled water for drinking purposes" (Pak
Tribune, 2005).
2.2
As a developing country with a large area and population, it is a major challenge to develop an
arrangement where the general public could be facilitated with access to clean drinking water. To
address the challenge, Government of Pakistan initiated Clean Drinking Water Initiative (CDWI) and
1
A recent report by the Ministry of Science and Technology is quoted as saying that "about 70 per cent of the Pakistani
population has no access to safe drinking water" [The News International, Pakistan, 15 Dec 2005]. To add to the confusion,
UNICEF states that in 2002 90 per cent of Pakistanis had improved access to drinking water.
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Clean Drinking Water for All (CDWA) programme under its commitment to Millennium Development
Goals (MDG). However, the programmes faced serious operational and implementation difficulties due
to a lack of proper risk identification in their planning stages, and by not implementing Strategic
Environmental Assessment (SEA) while developing the programmes. Even though the CDWA programme
is in its advanced stages of implementation, issues related to its execution are being evaluated for future
endeavors.
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Rationale for SEA
3.1
In Pakistan, environmental legislation started with creation of the Pakistan Environmental Protection
Ordinance (PEPO) of 1983 which was later replaced by Pakistan Environmental Protection Act 1997.The
act evolved as a legal binding for incorporating environmental considerations into development projects
(Aslam, 2006). Although Environmental Impact Assessment (EIA) studies have become requirement for
development projects but need for SEA is still unexplored. Institutional setups, lack the ability to foresee
the environmental degradation due to the absence of strategic mechanism in development and
planning. SEA is currently not a legal requirement in Pakistan and to date no formal SEA has been
undertaken to assess the environmental consequences or effects of policies, legislations, programmes
and development plans.
3.2
Existing act and EIA regulation has not been effective to address the environmental issues of Pakistan.
The country is facing continued environmental degradation due to lack of strategic approaches in
development and environmental conservation. Traditional environmental assessment tools, developed
primarily for project level planning and management, are less effective when applied to policies, plans
and programmes (OECD, 2006). CDWA and many other similar interventions are experiencing difficulties
relating to design and implementation. Although several efforts have been made to improve the
country’s overall environment, which include, donor funded projects and government initiatives.
However need to improve the existing programme implementation approach remained unattended.
While SEA approaches are widely recognized to be the most appropriate response to this new need,
however ways to operationalise SEA in practice have been varied among countries (Ahmed and SanchezTriana, 2008).
3.3
Government of Pakistan has recently initiated National Impact Assessment Programme (NIAP) with the
support of Embassy of the Kingdome of the Netherlands and Netherlands Commission for
Environmental Assessment (NCEA). NIAP aims to contribute to sustainable development in Pakistan
through strengthening its EIA processes and by introducing SEA in development planning. Improved EIA
will lead to more environmentally conscious development at the project level, whereas SEA introduction
will facilitate improved planning by the integrating potential impacts into plan development and
decision-making, and, through improved coordination between the authorities involved in planning
(IUCN, 2009).
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Programme at Glance
4.1
Objective
In 2004, the Government of Pakistan aimed at implementing the targets set in the action plan approved
at World Summit on Sustainable Development Johannesburg, 2002 for achieving MDGs. Government of
Pakistan initiated CDWI and CDWA Programmes to achieve the targets. The considered targets were:
“Halve by 2015 the proportion of people without sustainable access to safe drinking water”
“Safeguard human health, including reduction in the mortality rate (associated with lack of access to
safe drinking water, inadequate sanitation and poor hygiene), by improving the quality of drinking
water”
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4.2
Scope
In first phase of the programme (CDWI), the scope was limited to installation of one WFPs at each
district that later expanded to one at each Tehsil (544). The objective was to provide general public with
access to clean drinking water and, to improve health indicators. Without properly assessing the
associated implementation issues, the government initiated its second phase, CDWA programme, with
the same objectives but wider coverage area. The scope of CDWA programme was increased to
installation of 6035 WFPs having purification capacity of 8000 liters per hour in each union council. Later
this number increased to 6626 with engagement of additional finances. Reverse osmosis, chlorination
and ultra filtration technologies were selected for the water purification. Table 1.1 shows some of the
installed WFPs at various locations.
Table 1.1: WFPs at various locations in Pakistan
Photos by: Sahfi Agha, Zonal Project Manager, CDWA Programme
4.3
CDWA Methodology
The programme was implemented with joint support of federal and provincial government. The federal
government was responsible for:




Pre-qualification of Firms;
Selection of technology;
Water quality survey of selected sites;
Allocation of funds to provinces/special areas for:
- Capital expenditure
- Three years Operations & Maintenance
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The provincial government selected the locations for each WFP primarily at government owned land
through Tehsil Municipal Administration (TMAs). Contractor firms were hired for WFP establishment
and installation, whereas, the technology to be deployed was considered based on the water quality at
each site. In addition, provincial government was also responsible for regular administration and for the
supervision of plants and, frequent water analysis. Overall financial support was provided by the federal
government through the Public Sector Development Programme (PSDP). Each province established
programme implementation and monitoring unit for an effective execution. Operational and
maintenance cost of the programme was arranged through PSDP for three years. However the financial
sustainability of the programme during the entire operational phase was not evaluated.
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Observations and Lesson Learned
5.1
These observations and lesson learned are based on analysis of acquired data from programme
management and literature search. Documents including PC-1(Performa for Development Projects),
programme progress and monitoring reports have also been consulted.


5.2
Absence of national water policies dealing with water management at a broad level.
Alternatives to achieve the same programme objective were not considered e.g improvement of
existing schemes vs. CDWA.
 Despite of large geographical scope of the programmme, no feasibility and environmental
assessment study was conducted.
 Unplanned expansion of scope without considering the geographical boundaries (hilly terrain).
 Site and technology selection criteria were inadequate in the programme design.
 The progamme design did not foresee the lack of institutional capacity within implementing
ministries.
 Programme execution encountered governance lapse due to transfer of authority from ministry of
environment (2004) to ministry of industries production and special initiatives (2006) then to
ministry of special initiatives (2008).
 The programme faced a top driven approach that led to mismanagement at grass root level. Lack of
participatory strategies lead to lack of ownership.
 Provision of operations and maintenance of the installed plants in terms availability of resources for
continued operation were not considered.
 Backup systems for power generation to operate the WFPs in the absence of power supply from
national grid were not supported.
 Responsibility was given to the local government for ground work had worsened the situation where
certain programme components faced high political influence and vested interest.
In addition, the programme involved consultants for purchase and installation of WFPs and
responsibility was laid on the respective provincial and federal implementation units. Selection of
consultants encountered political influence and corruption. With poor financial mechanisms to manage
the available financial resources, the government funding encountered uncertain delays. The
implementation of the programme lagged behind and eventually failed. The total resources of Rs.
15,843 Million (USD 262 M) were spent and Table1.2 shows the turned down progress.
Table1.2: Progress
Phase
Planned
Installed
Operational
Non- Operational
Phase 1: CDWI
544
406
283
123
Phase 2: CDWA
6626
1144
678
466
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6
Possible Benefits of SEA
6.1
SEA improves decision making related to policies, plans and programmes. To ensure integration of
environmental considerations, established environmental assessment tools at the project level need to
be complemented by approaches fully adapted to policies, plans and programmes. SEA calls for the
“integration of the principles of sustainable development into country’s policies and programmes”. As
generally understood, SEA is a systematic and anticipatory process, undertaken to analyze the
environmental effects of proposed plans, programmes and other strategic actions and to integrate the
findings into decision-making(OECD,2006).
6.2
SEA applied in the water sector offers an additional mechanism to promote environmental concerns
within water resource management (World Bank, 2007). CDWA programme is an example where critical
environmental, social and economic considerations were not taken up at the design phase. SEA
considers evaluation of alternatives that leads to selection of appropriate options for the programme
design and implementation. Social, economic and environmental aspects are considered while applying
SEA that may have lead to the sustained programme output. In CDWA programme, SEA may have
allowed identifying alternative means to achieve the targets of the programme. Water quality surveys of
the programme identified that the quality is acceptable at source of extraction and deteriorates on
supply paths. Customized approach according to each province would have created innovative
opportunities to address the issues. For example in certain areas of Punjab, where water supply
schemes exist but poorly maintained, improvement in the supply system may have provided access to
clean drinking water. Similarly in northern hilly areas, improvement in conventional means of obtaining
water from springs would have adequately provided the solution. In certain areas of Balochistan,
improvement in traditional karaiz system may have helped. In CDWA, hydrogeology study of the
programme area was conducted but not consulted for site selections and implementation plan. SEA can
help building a coordination mechanism in order to acquire and make use of available knowledge
resources in an efficient manner. SEA of the programme may have allowed generating an efficient
environmental management plan for improved implementation.
6.3
SEA follows the process of public consultation in which stakeholders are approached for their concerns
regarding development activity, plans, regulations, policies and strategies in the country. Later these
concerns are addressed through change in design or proper management practices. During the recent
years environmental sensitivity has increased in the country. One example is Lahore canal road
extension project in which general public and NGOs approached judiciary to resist the development that
cause environmental degradation. SEA may have allowed developing mutual ownership of the
programme among involved authorities and the interested sectors of the population, through public
involvement. It may have supported in establishment of framework with the involvement of
stakeholders leading to a decentralized mechanism for programme implementation, thus, replenishing
the financial loss incurred. SEA may have identified issues through public involvement based on previous
experiences of locals and geography of the area. The response to the concerns of the public may have
enabled improved design and implementation, inturn, leading to success of the programme.
7.
Challenges for SEA in Pakistan
Introducing SEA is fundamentally a task of changing attitudes, the culture of organizations and
professional disciplines, and a change in power relationships between different parts of government.
However following challenges may likely to arise with SEA application in Pakistan:

SEA is a new tool and more complex than EIA and is not understood by many, in Pakistan. Majority
of the environmental professionals still think of it as a product and not a tool or a process. The tool
and materials with specific context to Pakistan are also not available.
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





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Absence of proper coordination mechanism and appropriate management tools to introduce SEA in
Pakistan.
Lack of understanding of the SEA as a tool among decision-makers, judiciary and other relevant
stakeholders, and required capacity within the country (e.g. consultants / experts, EPA officials) to
implement effectively.
Non-availability of trained or qualified human resources for carrying out SEA.
Non-availability of financial support where environment is a less priority (shortfalls in funding).
Lack of public awareness.
Limited involvement of communities, non-governmental organizations (NGOs) and the private
sector.
Conclusion
Based on carried out analysis, it can be stated that SEA could have facilitated design and implementation
of CDWA programme. In Pakistan, various policies, legislation, strategies, plans and programmes are
underway that require SEA, so that their implementation can lead to an enhanced sustainable
development. However, with less enforcement of existing environmental legislation, SEA remains an
unsolved question. Whereas more and more policies, legislation, strategies, plans and programmes,
involving huge finances and infrastructure development are facing difficulties, the need of SEA is
emerging as a solution. But, the planning and implementing authorities still lack capacity to relate
shortfalls to absence of SEA regime. Therefore, there is a need to develop acceptability among the
planning and executing authorities on SEA prior to introduction as a legal binding in Pakistan. SEA
initiation in Pakistan would require sustained capacity building, awareness, and, introducing new
insights, concepts and skills to staff in all sectors at earlier stages of SEA conceptualization.
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References
1. Ahmed, K. and Sanchez-Triana, E. (2008). Strategic Environmental Assessment for Policies: An Instrument
for Good Governance. Washington, DC: The World Bank.
2. Aslam, F. (2006), Environmental Impact Assessment in Pakistan – Overview, Implementation and
Effectiveness (Master Thesis), Kungl Tekniska Högskolan (KTH) Royal Institute of Technology,
Stockhomes.
3. Organization for Economic Co-operation and Development (OECD). (2006), Applying Strategic
Environmental Assessment: Good Practice Guidance for Development Co-operation, Development
Assistance Committee (DAC) Guidelines and Reference Series, Paris: OECD.
4. World Bank. (2007), Strategic Environmental Assessment and Integrated Water Resources Management
and Development. Washington, DC: The World Bank.
5. IUCN Pakistan.(2009), National Impact Assessment Programme, Pakistan: Ministry of Environment,
Planning Commission of Pakistan and IUCN-Pakistan.
6. Pak Tribune. (2005, December 21). Only 19.4pc people have access to clean drinking water: Report, Pak
Tribune, page number(s). Retrieved from http://paktribune.com/news/index.
7. Ministry of Environment. (2006) Performa for Development Projects (PC-1) Clean Drinking Water For All
Programme. Government of Pakistan.
8. Ministry of Environment. (2004), PC-1 Clean Drinking Water Initiative. Government of Pakistan.
9. Progress, review and monitoring reports of CDWI and CDWA. Government of Pakistan.
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